Ukraine: Cabinet of Ministers adopts new APA procedures
On 28 October 2021, the Cabinet of Ministers of Ukraine has adopted new procedures of preliminary coordination of advance pricing agreements (APAs) in controlled transactions, as a result of which agreements on preliminary coordination of pricing,
See MoreVietnam: MoF implements new rules on Advance Pricing Agreements
On 18 June 2021, the Vietnamese Ministry of Finance (MoF) has issued Circular 45/2021/TT-BTC, which sets out new rules on Advance Pricing Agreements in Vietnam. The key measures of the Circular are listed below: Transactions covered by
See MoreCosta Rica: Ministry of Finance issues resolution on APA procedures
On 24 March 2021, the Costa Rican Ministry of Finance released a Resolution No. DGT-R-14-2021, providing new guidelines on advance pricing agreements (APAs). The resolution provides the details guidelines of APAs procedures including definitions
See MoreGeorgia: MOF publishes decree amending transfer pricing rules for APAs
On 2 March 2021, the Georgian Ministry of Finance published Decree No.45 amending the Georgian transfer pricing rules regarding the Unilateral Advance Pricing Agreement (APA). The decree amends the APA clauses, most importantly reducing the filing
See MoreSouth Korea enacts tax revision bill for 2021
At the end of December 2020, South Korea has enacted a tax revision bill for 2021, which was passed by Korea’s National Assembly on 2 December 2020. The tax revision bill generally effective from fiscal years beginning on or after 1 January 2021.
See MoreAustralia updates APA guidance
On 3 December 2020, the Australian Taxation Office (ATO) published an updated law administration practice statement about the advance pricing arrangements (APA) program. The updated guidance (PS LA 2015/4) reflects changes to the APA
See MoreItaly publishes draft Budget for 2021
On 20 November 2020, the Italian Government published an updated version of the draft budget law for the year 2021, which is currently under discussion within the Italian Parliament. Following tax measures contained in the Draft Budget relate
See MoreMexico: Executive Branch submits 2021 economic proposal to Congress
On 8 September 2020, the Mexican Executive Branch has submitted Economic Package for fiscal year 2021 including a proposal of Tax Reform. The proposed 2021 Tax Law clarifies income tax law, value-added tax (VAT) law, and federal tax code. Tax key
See MoreSingapore publishes transfer pricing guidance in response to the Covid-19 outbreak
On 8 September 2020, the Inland Revenue Authority of Singapore updated its website by including guidance regarding transfer pricing in response to the Covid-19 pandemic. The guidance is provided in a following question and answering
See MoreGreece: Parliament published two Laws to introduce various changes in transfer pricing context
On 31 July 2020 and on 29 July 2020, the Greek Parliament Officially published two Laws, L. 4714/2020 and L. 4712/2020 respectively regarding various sections of transfer pricing. The two Laws cover the following changes: Tax dispute Resolution
See MoreMalaysia: IRB posts FAQs on advance pricing agreement due to coronavirus pandemic
On 16 June 2020, the Malaysian Inland Revenue Board posted online FAQs on advance pricing arrangement (APA) procedures for businesses due to the coronavirus pandemic. The questionnaire covers the filing of new APA applications; the treatment of
See MoreUS: IRS announces to change the procedures for filing MAP and APA
On 11 May 2020, IRS officials announced certain modifications to procedures for filing documents under Rev. Proc. 2015-40, 2015-35 IRB 236 (mutual agreement procedure (MAP) requests), and Rev. Proc. 2015-41, 2015-35 IRB 263 (advance pricing
See MoreIndonesia publishes new regulations concerning advance pricing agreements
On 18 March 2020, the Indonesian Ministry of Finance released 22/PMK.03/2020 which updates the Advance Pricing Agreements (“APA”) regulations. The new regulations, effective 18 March 2020, include the following amendments: Previously
See MorePoland publishes a law implementing EU directive on dispute resolution and new provisions on APAs
On 14 November 2019, Poland published the Law of 26 October 2019 on resolution of disputes over double taxation and the execution of advance pricing agreements (the “Act”), which generally entered into force on 29 November 2019. The law
See MoreGermany publishes new draft of DAC 6 implementation law
On 26 September 2019, federal government of German issued a draft proposal regarding the implementation of mandatory disclosure rules pursuant to the EU’s Council Directive 2018/822 of 25 May 2018 (commonly referred to as DAC 6) into Germany’s
See MoreKazakhstan: Resolution No. 528 of 27 August 2018 publishes for amending APA process
According to Resolution No 528 of 27 August 2018 published on 6 September 2018, the review committee must complete its review within 60 working days of receipt of the application. If the application is approved, the signed contract should be sent to
See MoreTurkey: General Communiqué No. 3 regarding APAs publishes in the official gazette
The General Communiqué No. 3 regarding application process of Advance Pricing Agreements (APAs) was published on December 7, 2017 in the official gazette. It was entered into force on the similar day of its publication in the official gazette. The
See MoreMorocco: New procedures for APAs
Morocco published a Decree No. 2.16.571 of 3 July 2017 in the Official Gazette No. 6594 on August 10, 2017 that describes the procedure for concluding advance pricing agreements (APAs). This decree was published in Arabic language. For example, a
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